Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
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Special audit u/s 142(2A) - Complexity and Volume of Transactions - Reasonable Opportunity to be Heard - Despite recognizing a breach of natural justice due to the insufficient response time, the High Court ruled that this breach did not cause substantial prejudice to the petitioner. The court emphasized the importance of a prima facie assessment for special audits and supported the Assessing Officer's discretion in such matters. Consequently, the court extended the audit report submission deadline and limited the audit scope, ensuring the petitioner's rights were protected while upholding the Revenue's interests.
Special audit u/s 142(2A) - Complexity and Volume of Transactions - Reasonable Opportunity to be Heard - Despite recognizing a breach of natural justice due to the insufficient response time, the High Court ruled that this breach did not cause substantial prejudice to the petitioner. The court emphasized the importance of a prima facie assessment for special audits and supported the Assessing Officer's discretion in such matters. Consequently, the court extended the audit report submission deadline and limited the audit scope, ensuring the petitioner's rights were protected while upholding the Revenue's interests.
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